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SHIELD PACKAGING

Administrative - Formal · FY2024 · — · — · 3603810440

Penalty
Cost recovery
Compliance action

Case

Case Number
01-2024-1001
Type
Administrative - Formal
Lead
EPA
Outcome
Multimedia
Self-disclosure
N

Defendants (1)

Summary

On November 21, 2023, EPA issued an administrative compliance order (AO) under the Clean Air Act (CAA) to Shield Packaging Co., a company that manufactures aerosol products at its facility in Dudley, Massachusetts. Shield Packaging Co. is subject to risk management planning (RMP) regulations and the General Duty Clause (GDC) promulgated pursuant to Section 112(r) of the Clean Air Act because the company uses and stores large quantities of flammable chemicals in its manufacturing process. An EPA inspection of the facility found, among other things, that the company failed to update its Process Hazard Analysis, to complete an RMP compliance audit, to maintain a written plan to maintain the mechanical integrity of its process equipment, ignored the recommendations for mechanical integrity documented by inspections conducted pursuant to applicable standards, and failed to follow recommendations and requirements of applicable standards for flammable liquid storage tanks. The AO requires the company to develop and implement a work plan to address the RMP and GDC violations found at the facility. CAA Section 112(r) requirements are not delegated to the Commonwealth of Massachusetts, but EPA will share a copy of the AO with the Commonwealth.

Source

Authoritative
EPA ECHO
Machine
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